Privacy Statement & SFDR

October 2023

This Privacy Statement provides information on how Capital Mills Invest b.v., its subsidiaries and the companies for which investment management activities are performed (referred to collectively as Capital Mills) process data from clients, suppliers and business associates. This Privacy Statement does not concern the processing of the personal data of employees of Capital Mills.

Our contact details:

Capital Mills Invest b.v.
Haarstraat 25
4201 JA Gorinchem

Purposes for which we process your personal data

We process data for the following purposes:

  1. If you contact Capital Mills (online or offline), we will use personal data such as your email address, name and telephone number. The basis for this is our legitimate interest in exchanging information with you. We will store your data so that we can exchange information with you in future, should it be necessary to do so.
  2. Compliance with statutory obligations and protection of Capital Mills’ interests. If you do business with us, or intend to do business with us, we will process your personal data for the purposes of assessment and acceptance, in connection with a contract or its performance, or an audit or legal proceedings. We may also use your personal data when checking whether you appear on a sanctions list or when performing due diligence in relation to existing or future investments by companies connected with Capital Mills.

Source of processed data

If we process personal data that we have not obtained from you, then that processing will always take place in connection with an agreement concluded with your or in preparation for a future agreement. That data will be obtained from public sources and registers (for instance from the Chamber of Commerce) or from consultants, in connection with an agreement to which you are party or an agreement with a firm at which you hold a position.

Disclosure of your personal data

Our firm will only disclose your personal data to third parties if obliged to do so by law or if necessary for the performance of an agreement that has been concluded.

Storage of your personal data

Once an agreement with you has been terminated, we will destroy all data that we are not required to retain by statute or regulations. An exception applies to publicly available information that is relevant for the purposes of any future contact (for example, email address, telephone number, address, LinkedIn details and information published by the Chamber of Commerce).

Your rights in relation to the personal data that we process

If you wish to exercise your rights under the General Data Protection Regulation, such as the right of access or rectification, the right to be forgotten or any other rights, please submit your request to us by email.

Data Protection

We use various cloud services to store your information. We only use services that operate using secure internet connections and configure database authorisation in such a way that information is only accessible to those who need it.

Force majeure, restrictions and complaints

Capital Mills endeavours to comply with your rights under the General Data Protection Regulation. However, as there are security risks associated with data transfers over the internet that cannot reasonably be eliminated, Capital Mills is unable to offer any guarantees in this respect. Capital Mills stores data in systems that comply with generally accepted security standards. We store hard copy data in a locked room that cannot be accessed by unauthorised persons except by forcing entry.
In relation to the data provided under any agreements, we will clearly indicate how that data will processed and where it will be stored. If you believe that these procedures are inadequate, we expect you to notify us, in which case we will terminate our agreement with you or decline to conclude an agreement with you.


Capital Mills Invest B.V. (“Capital Mills”) makes the following disclosures in accordance with the EU Sustainable Finance Disclosure Regulation (1019/2088) (“SFDR”) when acting as a registered AIFM.

Sustainability risk policies

When making investment decisions, Capital Mills takes sustainability risks into account. Capital Mills identifies and assesses potential sustainability risks that, if it were to occur, would cause a real or potential material adverse effect on the value of the (potential) investment. Investment decisions are made on the basis of pre-defined criteria that need to be met.
During the various stages of a portfolio journey, Capital Mills considers sustainability factors as integral part of the (pre) investment analysis, the day-to-day management of portfolio companies and eventually as part of the exit considerations.
Capital Mills does not make disclosures on the adverse impacts of its investment decisions on sustainability factors.
Capital Mills is labelled as an article 6 fund under the EU’s Sustainable Finance Disclosure Regulation (SFDR).

Integration of sustainability risks into remuneration policies

We recognize the risk that if not appropriately structured, the remuneration policies and the incentives they create could lead to negative impacts on Sustainability Risks. Therefore, we have adopted a remuneration policy which reduces sustainability risks.


Capital Mills Invest BV

Haarstraat 25

4201 JA Gorinchem